Griffin v. Breckenridge
Griffin v. Breckenridge is a significant U.S. Supreme Court case decided on June 7, 1971, that expanded the scope of federal civil rights protections. The case arose from a violent incident that occurred in 1966, where Lavon and Calvin Breckenridge attacked a group of African Americans suspected of being civil rights activists on a Mississippi highway. This group, which included the plaintiff Griffin, was subjected to severe physical abuse and intimidation, prompting them to seek legal redress under federal law.
Initially dismissed by a federal district court based on a prior ruling, the case was appealed and brought to the Supreme Court. The Court ultimately ruled unanimously, interpreting federal law, specifically Title 42 of the U.S. Code, section 1985, to extend protections against private conspiracies that sought to deprive individuals of their civil rights. This landmark decision signified a crucial advancement in civil rights law, asserting that state action was not a prerequisite for invoking federal protections against such conspiracies. By doing so, Griffin v. Breckenridge reinforced the rights to free speech, assembly, and movement, thereby contributing to the ongoing efforts to safeguard civil liberties in the United States.
Griffin v. Breckenridge
Griffin v. Breckenridge, decided June 7, 1971, extended federal civil rights guarantees of equal protection of the law to the protection of personal rights. On July 2, 1966, a group of African Americans who were suspected of being civil rights workers were halted on a Mississippi highway near the Alabama border by Lavon and Calvin Breckenridge, who purposely blocked the road with their car. The Breckenridges forced the African Americans from their vehicle and then subjected them to intimidation by firearms. They were clubbed about their heads, beaten with pipes and other weapons, and repeatedly threatened with death. Although terrorized and seriously injured, the African Americans (who included Griffin) survived. They subsequently filed a suit for damages, charging that they had been assaulted for the purpose of preventing them and “other Negro-Americans” from enjoying the equal rights, privileges, and immunities of citizens of the state of Mississippi and of the United States, including the rights to free speech, assembly, association, and movement, and the right not to be enslaved.
A federal district court dismissed the complaint by relying on a previous U.S. Supreme Court decision, Collins v. Hardyman (1951), which in order to avoid difficult constitutional issues had held that federal law extended only to “conspiracies” condoned or perpetrated by states. That is, the Court tried to avoid opening questions involving congressional power or the content of state as distinct from national citizenship, or interfering in local matters such as assault and battery cases or similar illegalities that clearly fell under local jurisdiction.
The Collins case, however, had been decided a decade before the nationwide civil rights movement of the 1960s, a period marked by the enactment of a new series of federal civil rights laws as well as by attentive regard by the U.S. Supreme Court of Chief Justice Warren Burger to cases involving civil rights violations. The Burger court heard the Griffin case on appeal.
The Supreme Court’s unanimous decision in Griffin was delivered by Justice Potter Stewart on June 7, 1971. The Court broadly interpreted the federal statute under which Griffin brought damages, Title 42 of the U.S. Code, section 1985. Section 1985 stipulated that if two or more persons conspired or went in disguise on public highways with the intent to deprive any person or any class of persons of equal protection of the laws or of equal privileges and immunities under the laws, a conspiracy existed and damages could be brought. The Court waived consideration of whether the Collins case had been correctly decided. Instead, reviewing previous civil rights legislation, starting in 1866, the justices determined that the language of the federal statute clearly indicated that state action was not required to invoke federal protection of constitutionally guaranteed personal rights from impairment by personal conspiracies. Griffin effectively extended federal safeguards of civil rights to reach private conspiracies under the Thirteenth Amendment as well as under congressional powers to protect the right of interstate travel.
Bibliography
Cogan, Neil H. “Section 1985 (3)’s Restructuring of Equality: An Essay on Texts, History, Progress, and Cynicism.” Rutgers Law Rev. 39.4 (1987): 515–590. Print.
McDonald, Janis L. “Starting from Scratch: A Revisionist View of 42 U.S.C. 1985 (3) and Class-Based Animus.” Connecticut Law Rev. 19.3 (1987): 471–511. Print.
Pinzow, Lee. “Is It Really All about Race?: Section 1985(3) Political Conspiracies in the Second Circuit and Beyond.” Fordham Law Rev. 83.2 (2014): 1031. Supplemental Index. Web. 23 Apr. 2015.
Sheehan, Daniel P., and Robert D. Rapp. “The Scope and Application of 42 U.S.C. 1985(c): Beyond the Fourteenth Amendment Question.” Antioch Law Jour. 2.1 (1982): 131–157. Print.
White, John Valery. “Vindicating Rights in a Federal System: Rediscovering 42 U.S.C. 1985(3)’S Equality Right.” Temple Law Rev. 1 (1996): 145–243. Print.